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Section 153A

Latest Articles


Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 1560 Views 0 comment Print

Special vs General: Time Limit Conflict between Section 144C(13) and Section 153 of Income Tax Act, 1961

Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...

December 16, 2025 2604 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...

October 30, 2025 1968 Views 0 comment Print

FAQs on Prosecution provision under Income Tax Act, 1961

Income Tax : A summary of prosecution offences under Chapter XXII of the Income Tax Act (Sections 275A to 280), detailing the rigorous imprison...

October 29, 2025 6918 Views 0 comment Print

Compounding of offence under the Income-tax Act, 1961

Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...

October 17, 2025 2940 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2127 Views 0 comment Print


Latest Judiciary


Alleged Accommodation Entry Addition deleted Due to Loan Repayment Misclassification

Income Tax : The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as i...

April 16, 2026 279 Views 0 comment Print

Reopening Fails on Both Counts: Invalid Sec 148A Notice and Time-Barred Sec 148 Render Assessment Void

Income Tax : The issue was whether a notice granting less than the statutory minimum time is valid. The tribunal held that giving less than 7 d...

April 16, 2026 162 Views 0 comment Print

No reassessment beyond 3 years without proper sanction of prescribed higher authority

Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...

April 15, 2026 249 Views 0 comment Print

ITAT Rajkot: Addition Based on ‘Dump Excel Sheet’ Deleted – No Evidence, No Tax

Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...

April 14, 2026 690 Views 0 comment Print

Third-Party Excel Sheets & Statements Without Corroboration Have No Evidentiary Value

Income Tax : ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack ...

April 13, 2026 207 Views 0 comment Print


Latest Notifications


Selection of Case of Search Years in ITBA Assessment module

Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...

September 12, 2019 2466 Views 0 comment Print


AO’s admission of not issuing Section 143(2) notice invalidates assessment: ITAT Chandigarh

November 25, 2025 555 Views 0 comment Print

Tribunal held that assessment was void because no notice under Section 143(2) was issued, confirming that such omission cannot be cured and invalidates entire assessment.

Madras HC Upholds Income Tax Search After Finding Valid Reason to Believe

November 25, 2025 678 Views 0 comment Print

The Court held that the search was valid after reviewing the recorded reasons and information. It ruled that jurisdiction existed under Section 132 and that challenges to procedural aspects did not invalidate the search.

Bogus Sub-Contractor Additions Deleted; 132(4) Statements Insufficient

November 24, 2025 636 Views 0 comment Print

The Tribunal examined alleged bogus payments to 27 sub-contractors treated as undisclosed income. While the Assessing Officer made large additions, the assessee provided affidavits confirming genuineness. The ruling partly allowed the appeals, stressing careful verification of evidence rather than assumptions.

Group ITSC Findings Cannot Be Applied, U/s 153A, Subsidiary Protected

November 24, 2025 213 Views 0 comment Print

ITAT Delhi ruled that additions under section 153A cannot be made without incriminating material specific to the assessee. All unbooked commission additions for AYs 2012-13 to 2016-17 were deleted.

Section 153A Assessment Based Solely on Documents Seized from Third Party Invalid: ITAT Delhi

November 23, 2025 1080 Views 0 comment Print

ITAT held that additions under section 153A cannot be made if no incriminating material is found at the assessee’s premises; third-party documents should be invoked via section 153C.

Documented LTCG on Listed Shares Not ‘Undisclosed Income’ for 271AAB Penalty

November 22, 2025 342 Views 0 comment Print

ITAT Jaipur clarified that penalty under section 271AAB is not mandatory and requires proper examination of evidence and explanation by the assessee before imposition. Mere surrender of income does not constitute undisclosed income.

Section 271AAB Penalty Not Leviable on Fully Recorded, Documented LTCG

November 22, 2025 456 Views 0 comment Print

Tribunal holds that surrendered LTCG cannot be treated as undisclosed income when fully recorded in books and supported by verifiable documents. Penalty under section 271AAB was therefore not leviable.

Invalid 153C Satisfaction Note – No Nexus Between Seized Diary & Assessee; Addition Deleted

November 21, 2025 336 Views 0 comment Print

The Tribunal held that a cash ledger found during a third-party search could not trigger Section 153C when the assessee’s name was absent. It ruled that additions fail without a direct link to the assessee.

Mechanical 153D Approval & No Incriminating Material – Delhi ITAT Quashes Entire 153A Assessments

November 21, 2025 342 Views 0 comment Print

The Department could not produce a single document seized from the assessee, relying only on third-party statements, which are not incriminating material. The JCIT’s same-day clearance of multiple assessments without analysis led to the assessments being quashed.

Mechanical 153D Approval Vitiates Entire 153A Block – Delhi ITAT  

November 21, 2025 354 Views 0 comment Print

The JCIT granted approval despite receiving only draft orders and no supporting evidence, demonstrating a mechanical process. The Tribunal held that such superficial approval violates judicial standards, leading to the quashing of all assessments.

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